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August 2020 Newsletter

Newsletter: August 2020

The latest news regarding WEEE, e-waste, battery and packaging compliance

Ontario's New Battery Law

Ontario battery recycling

The Province of Ontario in Canada has a new battery law that came into force on July 1 2020 as part of the Resource Recovery and Circular Economy Act: Ontario Regulation 30/20. Battery producers who place any sold-separately battery that weighs less than 5 Kg on the Ontario market are defined as obligated “Stewards”. Both single-use and rechargeable batteries are obligated. Stewards will be considered individually accountable and financially responsible for the resource recovery (reuse, refurbishment, or processing) of those end-of-life batteries that fall within the scope of obligated batteries.

The definition of a battery steward encompasses a variety of scenarios, but it does capture most sellers, with variables such as which party is the brand holder, their residency status in Ontario and Canada, and to whom the battery is sold. Some exemptions apply for specific scenarios.

Integrated batteries, meaning batteries that are sold already inside a product, are exempted from this law. However, a new electronic waste law is in the pipeline for Ontario and due to come into force early 2021. This is expected to encompass integrated batteries.

Requirements for compliance include free collection networks for consumers, the need for promotional and education materials until the end of 2022 to increase consumer awareness, and most producers will be likely to need to source services from a Producer Responsibility Organization to meet the legal obligations.

If your company sells portable batteries weighing less than 5 Kg on the Ontario market, or in any Canadian province, please contact Accerio for more details about your potential obligations.

UK Plastic Packaging Tax

From April 2022, the UK government will impose a £200 per tonne tax on plastic packaging that contains less than 30% recycled plastic. Plastic packaging is defined as packaging materials where plastic is the predominant material. The tax is designed to grow the recycled plastics market to meet increased demand and divert more waste from landfill. Most of the provisions have been finalized, however a few details are yet to be confirmed, including whether or not to exempt transit packaging intended only to protect products during transport.

This tax will apply to:

  • Large Producers: who place more than 10,000 Kg of plastic packaging on the UK market annually
  • UK Packaging Producers
  • UK Packaging Importers, if the packaging is produced outside of the UK
  • All packaging, regardless whether it is empty or filled, to all end users

This tax will not apply to:

  • Small producers: who place less than 10, 000 Kg of plastic packaging on the UK market annually
  • Foreign distance sellers (see above, the UK importer will carry obligation)

Quarterly reporting on packaging will be mandatory, with declarations required of all weights of packaging placed on the market (POM).  The tax applying to packaging in scope will be administered through Her Majesty’s Revenue and Customs (HMRC) Department, and unless packaging is declared – with evidence – to contain at least 30% recycled material, the tax will apply to the total weight POM.

April 2022 will be here before we know it, so it is advisable to look now at supply chains to determine the % recycled content of plastic packaging used, and if proof of the recycled content exists in the form of certification or specification sheets.

New Eco-Design Regulations

Eco Design repair screen

The new EU Eco-design regulations, adopted as part of the Circular Economy package’s Eco-Design Working Plan, are coming into force in 2021, with the objective of increasing the repair, reuse, and recyclability of the products targeted. The 10 regulations apply to all products in scope that are placed on the EU Market regardless of their country of manufacture.  The product categories targeted are:

  1. Household Refrigerators
  2. Refrigerators with a direct sales function (e.g. fridges in supermarkets, vending machines)
  3. Washing Machines
  4. Dishwashers
  5. Welding Equipment
  1. Electronic Displays (including most computer monitors and televisions)
  2. Light Sources and Separate Control Gears
  3. External Power Supplies
  4. Electric Motors
  5. Power Transformers

The Eco-Design Regulations have a direct application, with no need for transposition into local legislation. The 2021 deadlines vary, the first being March for electronic displays, April for external power supplies, July for electric motors and power transformers, September for light sources.

The new requirements are focusing on lower limits for the Energy Efficiency Index and are bringing new material efficiency specifications. The Regulations are strengthening the concepts of products designed for repair and reuse, and design for dismantling, recycling and recovering, in accordant with the Waste Hierarchy. More, specific information will have to be made available in the technical documentation and on the producer website, together with specific labelling requirements, especially for some plastic components.

For Producers it may impact on production strategies and costs, with the decision to be made whether to manufacture compliant product lines specifically to be sold in Europe or to make products bound for all geographies in line with these regulations.

If you are interested in more information regarding Eco-Design Regulations, please contact Accerio for an introduction to the new requirements.

The Impact of POPs

POPs Old monitor

From July 15, 2020 the recast EU Regulation on Persistent Organic Pollutants (POPs) came into force, repealing the previous POP’s Regulation. POPs are problematic for all biological life, and legacy Electronic and Electrical Equipment (EEE) containing these materials will now face increased treatment requirements, driving up WEEE treatment costs across Europe.

The new regulation aligns more closely with the REACH regulation and the Waste Framework Directive, with greater clarification of definitions to ensure unity across the EU. The list of POP chemicals included has been expanded, applying restrictions on the use of specific substances in manufactured products, as well as more detail of end-of -life treatment methods that must be used for certain products containing chemicals.

These chemicals are not as plentiful in current manufacturing as they once were but, they are still being collected in older WEEE processed. For example, many household electrical items, such as televisions and computer monitors, used to be manufactured using brominated flame retardants to reduce their risk of catching fire if overheating. These old items can no longer be recycled with other WEEE and must now be subject to thermal treatment at a hazardous waste plant.

As yet it is not clear how or when collective organizations and authorities will pass on the costs, or if they will instead absorb them, but it is probable that the increased handling overheads will translate into increase fees for Producers across the EU.

August 2020 Newsletter Read More »

November 2019 Newsletter

Newsletter: November 2019

The latest news regarding WEEE, e-waste, battery and packaging compliance

The Circular Economy:
Subscribe to a Sustainable Environment

The European Union recently presented the Circular Economy Package, which includes waste directives adopted by the European Parliament and the EU Council amending, among others The Waste Framework Directive (2008/98/EC).
The Circular Economy conceives a system where energy sources are renewable, a reduction in waste production, and waste viewed as a resource instead of a burden for society.

The ‘Waste Hyperarchy’ addresses the entire product cycle of production, consumption, waste management and market for secondary materials to achieve a more efficient use of primary and secondary resources.

Potential impacts on Producers of WEEE, Batteries, and Packaging Producers selling into the European Union include:

  • Economic benefits for Producers of products with more efficient and better ecological designs
  • Greater Extended Producer Responsibility costs for products with poorer ecological and lower efficiency performance of products
  • Increased regulation of:
    → Eco – design criteria
    → Product design
    → Use of hazardous materials
    → Product markings
    → Data collection methodology
    → Easier trade of ‘waste’ i.e. secondary materials
  • Packaging re-design to reduce superfluous secondary packaging and reduce single use plastics, especially those associated with food and beverages, and fishing gear
  • Products designed for Re-Use, Repair, and Recyclability, including repair manuals to be made available
  • Increased standards for chemical/pollutant content of product material composition
  • Requirement to increase of life-span of products

Accerio will keep you informed of practical impacts as they unfold.

Shipping electrical products for repair or re-sale: is it EEE, or is it WEEE?

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When transporting used EEE it is important to know what is required to avoid falling afoul of the European Union’s Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste (WSR). This is an important consideration when shipping the following:

  • End-Of-Lease electronic products
  • Used electrical products
  • Faulty or malfunctioning products
  • Electronic goods destined for repair reuse and re-sale

To qualify as EEE the goods must meet certain criteria. The way in which the ‘holder’ of the electrical products treats a product can be interpreted as an indicator of whether or not the goods are truly EEE or are waste. Specifically considered is the evidence of intent to re-use the goods or discard them as waste; it must be demonstrated that the goods are not to be discarded or intended to be discarded. To qualify as EEE:

  • The electrical goods should still be functional for the original purpose; this must be documented with an invoice and or statement to this effect
  • The goods are to be protected from damage in transit e.g. original packaging or other packaging
  • There must be evidence of testing for functionality
  • Malfunctioning electronic products that are intended for repair and re-use must demonstrate the potential for re-useability, that the re-use is certain, testing and or repairs necessary for the item to be reusable have been carried out, or will be carried out by specialized technicians on receipt of the shipment. Documentation of this is required
  • There must be some certainty of the re-use of the products
  • There cannot be intention to discard the products after the transportation, that they cannot be regarded as a burden for the purchaser
  • Redundant stock lines in unopened original packaging will be regarded as EEE
  • Documentation of any or all of the above must accompany the goods during transit, including a declaration the goods are not waste

A cautionary tale is the recent case in July 2019 of Openbaar Ministerie v Tronex BV, where a company was preparing to ship from The Netherlands to Tanzania a consignment of electric appliances consisting of a mix of warranty returns, redundant/old stock, and non-functioning appliances that were declared as to be repaired for re-sale.  The European Court of Justice handed down the ruling against Tronex BV as well as a hefty fine, because the shipment contained electrical items had not been packaged to protect some of the goods that were intended for repair, and there was no documentation about the repairs.

For Specifics on documentation required for shipping EEE and WEEE and further details please refer to the Shipment of WEEE Guidance document in the links below, which includes the requirements from Annex VI of the WEEE Directive 2012/19/EU.

  1. Shipment of WEEE Guidance document
  2. WEEE Directive Annex VI; Minimum Requirements for Shipments
  3. Openbaar Ministerie v Tronex BV
  4. OPINION OF ADVOCATE GENERAL KOKOTT delivered on 28 February 20191 Case C-624/17 Openbaar Ministerie v Tronex BV

EU Ecodesign Measures - New Regulations in Force

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On October 1st 2019, the EU Commission adopted 10 ecodesign requirements amending Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009. The objective is to reduce Europe’s energy bill through energy savings and to reduce greenhouse gas emissions, the main factor in climate change. These measures apply to the following products placed on the Union market, independently of where they are manufactured:

  • Refrigerators
  • Washing machines
  • Dishwashers
  • Electronic displays (including televisions)
  • Light sources and separate control gears
  • External power suppliers
  • Electric motors
  • Refrigerators with a direct sales function (e.g. fridges in supermarkets, vending machines for cold drinks)
  • Power transformers
  • Welding equipment

While refrigerators and welding equipment are for the first time in the spotlights, the other eight ecodesigns are already known in EU, being part of the 2009 legal framework.

The ecodesign measures primarily focus on the reparability and recyclability of the products, with a revision of the existing provisions for durability of lighting systems, water consumption for dishwashers and washing machines, and the marks on the chemical products, underlining the future relationship between Waste and Chemicals regulations.
With the energy labelling regulation, which complements the ecodesign specifications with mandatory labelling requirements, the Commission project targets:

  • The delivery of 167 TWh of final energy savings per year by 2030;
  • The reduction of more than 46 million tonnes of CO2 in the atmosphere;
  • European households save an average of 150 EUR per year.

The ecodesign Working Plan 2016-2019 is part of an ambitious project which aims to influence what happens during the use and end-of-life phases of certain products, not only in terms of energy consumption, but also in terms of waste management.

Year End Reporting: It is nearly that time again...

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The end of 2019 is approaching fast, and with it the end of year WEEE, Batteries, and Packaging reporting requirements. All Producers selling into the EU will be required to report, which makes for tight deadlines at a busy time of the year.

As a reminder, here are a few tips to make the process as streamlined as possible; please let us know here at Accerio if:

  • There have been any product changes, please send us SKU numbers, weights and technical specifications.
  • There are new reporting staff and or change of email addresses, please update our information so we can be sure to be in communication with the right people.
  • There has been any takeback or recycling by yourselves or any third parties, please send us the data and information.

It’s also a good idea to touch base with Authorized Signatories in your organization to remind them that some annual reports will require their signature, given it is an extra demand on them at a busy time of the year.

If you would like us to check through your data before the end of year to ensure that January is as stress free as possible, please feel free to contact your account manager.

On the Move

Accerio has outgrown the current space we occupy in the Netherlands and the time has come to relocate.

The big move is now complete, with the assistance of bicycles, ramps, stroopwafels and the local weather being nice enough to hold back snow and rain.

We now have larger premises in a great part of town east of the city centre at:

Panamalaan 8D
1019 AZ Amsterdam
The Netherlands

Please ensure you update our address in your records; our phone number will remain the same:

+31-20-716-3480

Please do stop by to say hello if you are nearby!

November 2019 Newsletter Read More »

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